of court proceedings over which that judge presides." The Senate Judiciary Committee has recommended that it be considered by the Senate as a whole. In 1965, the U.S. Supreme Court ruled, "The television industry, like other institutions, has a proper area of activities and limitations beyond which it cannot go with its cameras. That area does not extend into an American courtroom. On entering that hallowed sanctuary, where the lives, liberty and property of people are in jeopardy, television representatives have only the rights of the general public, namely, to be present, to observe the proceedings, and thereafter, if they choose, to report them." In the 1981 case Chandler v. Florida, the U.S. Supreme Court ruled that televising trials does not, per se, violate due process. Although the U.S. Constitution contains a public trial clause, it has been argued that the requirement of a public trial was created and satisfied when there were no broadcasters or telecasters and few newspapers. In some cases, jury deliberations have been publicly broadcast. Since 1955, the U.S. Supreme Court has made audio recordings of all its proceedings, which have been released more quickly over time. During the COVID-19 pandemic in the United States, the court started allowing the public to listen in real time. United Kingdom Photography and broadcasting of a Crown Court case in the United Kingdom was illegal from 1925 until June 2020 per code 41 of the Criminal Justice Act and the Contempt of Court Act. In 2004, a small number of cases in the Court of Appeal were filmed in a trial basis. Other courts have begun to allow photography and filming in the early 21st century; the Supreme Court has permitted filming since 2009 while the Court of Appeal has allowed it on a regular basis since 2013. The second trial in 2012 for the Murder of Arlene Fraser in the High Court of Justiciary was later broadcast on Channel 4. In June 2020, the Crown Court (Recording and Broadcasting) Order 2020 was passed. According to the Ministry of Justice, filming in the Crown Court is expected to commence as soon as practicable after recovery from COVID-19 disruption. Only the judge will be filmed, recording only sentencing remarks in serious high-profile criminal cases, as was the case with the sentencing of Ben Oliver in July 2022. Russell Causley, who was convicted of the murder of his first wife Carole,